Document JJzB8yr4M9rxBjOD0DGaZwL0Z

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CIDCAGO, ILLINOIS 60604 NOV 2 1 l019 CLEAN AIR ACT INSPECTION REPORT Grand Casino Mille Lacs, Onamia, Minnesota Jason Schenandoah, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Grand Casino Mille Lacs Facility Location: Grand Avenue, Onamia, Minnesota Date of Inspection: 9/23/2019 EPA Inspector(s): 1. Jason Schenandoah, Environmental Engineer Other Attendees 1. Todd Christopherson, Vice President of Facilities, Grand Casino Mille Lacs 2. Jim Hutchison, Electrician, Grand Casino Mille Lacs 3. Steve Meredith, HVAC Lead Technician, Grand Casinos Mille Lacs and Hinckley 4. Charlie Lippert, Air Quality Specialist, Mille Lacs Band of Ojibwe Indians 5. Sara Wandrei, Chemical Engineer, Barr Engineering Co. Contact Email Address: jhutchison@grcasinos.com; Charlie.Lippert@millelacsband.com; swandrei@barr.com Purpose of Inspection: To ensure compliance with the Clean Air Act. Full Compliance Evaluation. Facility Type: Hotel and casino with emergency generators Regulations Central to Inspection: NESHAP ZZZZ for reciprocating internal combustion engines, and 40 C.F.R. Part 82 for ozone depleting substances Arrival Time: 2:35 pm Departure Time: 3: 18 pm Inspection Type: D Unannounced Inspection 12:l Announced Inspection OPENING CONFERENCE 12:l Credentials Presented 12:l CBI warning to facility provided The following information was obtained verbally from Grand Casino personnel unless otherwise noted. Process Description: Two Caterpillar 3516 stationary, diesel, compression ignition (CI) engine/generator sets manufactured in 2001 (EU 003 in permit, 2000 kW) and 2004 (EU 001 in permit, 2068 kW), and two Caterpillar 3512 stationary, diesel, CI engine/generator sets manufactured in 2001 (EU 004 in permit, 1400 kW) and 2005 (EU 002 in permit, 1250 kW). The engines are used for peak shaving and backup power for the casino and hotel. Additionally, the facility operates a variety ofrefrigeration and comfort cooling systems for the casino/hotel. Staff Interview: Mr. Hutchinson mentioned that units were experiencing a pressure drops below compliance levels. He attributed the reduction in pressure drop to lower loads on the units due to changing many of the facility's lights to LED lights. He also stated that the Grand Casino is working with EPA permitting to undergo new stack tests to remedy the low pressure drop issues. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: All engines were visually inspected and total run hours and energy produced were recorded from the digital display screens. Photos and/or Videos: were not taken during the inspection. Field Measurements: were not taken during this inspection. Page 2 of3 RECORDS REVIEW For reasons of timeliness all records were requested to be stored on a thumb drive prior to arrival at the facility. EPA requested all data associated with the following list of documents. EPA reviewed the following list of records to determine compliance: 1. Maintenance records; 2. Catalyst inlet temperature, pressure drop across the catalyst and, run time data; 3. Performance test reports; 4. Semi-annual ZZZZ compliance reports; 5. HVAC technician certifications; 6. HVAC repair data; and 7. Part 71 semi-annual and annual reports. Concerns: Many instances of low differential pressure across catalyst on units EU00 I, EU002, and EU004. Some monitoring data was not recorded on all units. Catalyst inlet temperature was low on unit EU 004. No 40 C.F.R. Part 82 leak rate calculations. SIGNATURES Report Author: Page 3 of3